The Centers for Medicare & Medicaid Services (CMS) has published the proposed rule for calendar year 2025 titled “Medicare and Medicaid Programs: Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Payment Systems.” The 2025 OPPS proposed rule contains a market basket increase of 2.6 percent.
Unlike inpatient care where blood is included in a bundled payment of services, CMS makes separate payments for blood and blood products in outpatient care. In the 2025 OPPS proposed rule, CMS is suggests continuing the methodology used since calendar year 2005 to set the rates for blood and blood products. Within the 2025 OPPS proposed rule, CMS seeks comments on several items of note to the blood community:
- payments for certain cell and gene therapies including, “a Chimeric Antigen Receptor (CAR) T-cell therapy administration C-APC, with which the CAR-T or gene therapy would be integral, ancillary, supportive, dependent, or adjunctive to the primary C-APC service;”
- a recommendation of service improvement requirements for OB emergencies. The proposed rule does not require blood specifically, though it is suggested;
- an emergency services Condition of Participation (CoP) to improve readiness for hospitals with Emergency Departments that would require blood and blood products commonly used in lifesaving procedures “be kept in the hospital and be readily available for treating emergency cases.” It is noted that the requirement is flexible and does not require any specific items, but rather anticipates that each facility will determine what is needed based on their particular facility and patient population.”
Comments on the 2025 OPPS proposed rule are due September 9th. America’s Blood Centers (ABC) continues to review the proposed rule regarding its implications for community blood centers and will submit comments to CMS. ABC will continue to provide updates on its advocacy efforts.